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Co authored by Kim Kaseliones (BreakawayFunding.com) and Joseph Barisonzi (CommunityLeader). This is Part II of a three part series about Crowdfunding and Community Banks. As Part II in the series, Crowdfunding 101 for Community Bankers, this white paper provides community bankers with the information about and understanding of crowdfunding needed to build and present an irrefutable case for immediate implementation of a crowdfunding strategy. It presents this material as follows:-Provides a brief historical overview of crowdfunding in the United States; -Defines crowdfunding and other relevant terms, including the four primarymodels of crowdfunding; -Describes donation and reward/premium-based crowdfunding; -Explains the four key components of the JOBS Act of 2012 and the relevanceof this legislation to banks; -Discusses the critical role equity- and debt-based crowdfunding will play inthe future of the banking industry; -Establishes crowdfunding as a key player in the capital market movingforward; and -Sets the stage for community bank leaders to effectively use the two additional white papers in this series to instigate the proactive change and engagement in securities- based crowdfunding — critical to thriving in the competitive landscape being carved by the powerful wave of crowdfunding.
Citation preview
www.communityleader.com
Renewed Purpose and Survival through Crowdfunding.
by Kim Kaselionis and Joseph Barisonzi
Community Banks
book I, Version 1 (July 2013 )Part II: Crowdfunding 101 for Community Bankers
Abstract
As Part II in the series, Crowdfunding 101 for Community Bankers, this white paper
provides community bankers with the information about and understanding of
crowdfunding needed to build and present an irrefutable case for immediate
implementation of a crowdfunding strategy. It presents this material as follows:
Provides a brief historical overview of crowdfunding in the United States;
Defines crowdfunding and other relevant terms, including the four primary
models of crowdfunding;
Describes donation and reward/premium-based crowdfunding;
Explains the four key components of the JOBS Act of 2012 and the relevance
of this legislation to banks;
Discusses the critical role equity- and debt-based crowdfunding will play in
the future of the banking industry;
Establishes crowdfunding as a key player in the capital market moving
forward; and
Sets the stage for community bank leaders to effectively use the two
additional white papers in this series to instigate the proactive change —
engagement in securities- based crowdfunding — critical to thriving in the
competitive landscape being carved by the powerful wave of crowdfunding.
Crowdfunding 101 for Community Bankers
In recent months, the term, crowdfunding, has been thrown around like an inflatable
ball at a beach party. Many of the people who use the word, however, have a
limited and often inaccurate understanding of what really constitutes crowdfunding.
To complicate matters further, there are considerable differences between what is
understood to be crowdfunding in the general market and the legal definitions of
crowdfunding embedded in recent legislation and Securities and Exchange
Commission (SEC) rules.
Crowdfunding is a phenomenon permeating many sectors simultaneously. One
sector in which it is proving to have a significant impact is the banking industry. With
more alternatives to traditional funding popping up every day, it is no wonder bankers
are hungry for more information on crowdfunding and how it is likely to affect the
future of their business. The material below introduces the aspects of crowdfunding
most critical for community bankers to understand, including a definition, history,
overview of concepts, relevant legislation and major trends in the industry. After
reading this white paper, bank leaders will have the solid foundation of understanding
and facts they need to discuss and judiciously consider the different models of
crowdfunding as the basis for additional bank products and services.
From Ben Franklin to the Internet
While the actual term has only come into vogue over the past few years, the
concept behind crowdfunding has been around for centuries. In order to
understand crowdfunding at its core, it is helpful to know the history behind this
seemingly new phenomenon. Crowdfunding, as it turns out, has deep roots in the
American tradition.
Benjamin Franklin, whose many accomplishments include soliciting funds from
multiple investors to establish the first lending library in 1732, was also rumored to
have purchased America’s first printing press by soliciting orders from Philadelphia
business owners to pay for the initial purchase.i
Over 100 years later, Joseph Pulitzer raised over $100,000 to build a foundation for
the Statue of Liberty, receiving contributions from over 120,000 people in exchange
for printing their names in his newspaper.ii While Franklin and Pulitzer did not have
the terminology being used today, what they did was an early version of what has
become known as reward-based crowdfunding.crowdfunding strategy can harness
its energy to propel themselves back into position as formidable competitors and
effective supporters of their communities.
1
Security: Somethingprovided or pledged to
secure the fulfillment of anobligation. A security may or
may not be registeredand/or regulated
depending on whether ornot it meets certain criteria.
In the case of securities-based crowdfunding,
transactions will beregulated by the SEC
(pending publication of thefinal SEC rules).
"Community banking is, at its core, very democratic — a kind of 'for the people
– by the people' page out of the Constitution. Deposits are gathered from the
community and reinvested into the community driven by the decisions of leader
representatives of the community."
~ Kim Kaselionis, co-author and former CEO/Chairman of Circle Bank
www.communityleader.com
Issuer: A business ororganization raisingmoney through a portal.In securities-basedcrowdfunding, a securityis being “issued.”
Platform: The behind-the-scenes software andservicesthat allow the portal toeffectivelyconnect issuerswith investors from "thecrowd".Because "the crowd"is typically accessed viatheInternet, a platform usuallyfunctions on theWeb.
Whether welcome or not, crowdfunding has already begun to surge through the
financial sector and all signs indicate it is unlikely to subside anytime soon.
Community banks that wait to act—hoping to float over this wave of change—are
likely to be pulled down in the undertow. Engaging in crowdfunding is no small task;
in order to position their institutions effectively, bank leaders will have to persuade
board members, gain a basic understanding of crowdfunding as it relates to
community banking, consider the pros and cons associated with securities-based
crowdfunding, and identify an appropriate platform to meet their needs. Fortunately,
there are companies with the knowledge, experience and services necessary to
help community bankers catch the crowdfunding wave and maintain the ride as
effective advocates for their communities once again.
Crowdfunding Defined
The term, crowdfunding, is used by various people and organizations to describe a
multitude of activities. While there are slight variations in the way industry leaders
construe crowdfunding, it can generally be defined as follows:
Crowdfunding: The process through which an individual or organization initiates
a campaign to raise funds for a specific purpose by engaging “the crowd” via a
platform.iii
There are four primary types of crowdfunding: donation-based, reward/premium-
based, equity-based and debt-based, each of which is defined below. In order to
discuss crowdfunding astutely, bankers should also be familiar with the additional
terms noted in the sidebar as well.
The success of a crowdfunding campaign usually relies on small contributions from
multiple parties (i.e., “the crowd”) rather than large contributions from a few. By
connecting investors from “the crowd” with a campaign that interests them, the
platform enables participants to combine their economic power to support the
campaign, thus facilitating a successful raise for the issuer.
2
"Without the economic leadership of community banks, the economic
development—including affordable housing production—of our community
development financial institutions (CDFIs) and community development
corporations (CDCs) would be impossible."
~ Joseph Barisonzi, co-author & CEO CommunityLeader
Emerging Crowdfunding Models
As noted above, there are four primary types of crowdfunding models: 1)
Donations; 2) Reward/Premium; 3) Equity; or 4) Debt. Understanding the
distinctions between these is critical to recognizing the significance of crowdfunding
as it pertains to the present and future of the banking industry.
As a term, crowdfunding emerged in the context of the first two models: donation-
and reward/premium-based. In both of these models, the money donors provide is
legally considered, to be a “gift,” with no expectation of economic profit. As a result,
neither is considered by law to be a “security” transaction. This distinction has
allowed both models to flourish in an unregulated market.
Donation-based Crowdfunding
In the donation-based model, contributors make online donations or gifts to an
individual or organization’s campaign without any expectation of direct economic or
material benefit. The return, in this case, is a pleasant altruistic feeling and
sometimes a tax deduction. This type of crowdfunding is already used by
community banks to facilitate civic donation campaigns, such as a fund to assist
members of the community following a tragedy (e.g., medical expenses for serious
illness, loss of home, unexpected death of a family member).
In the donation-basedmodel, funders donate
money to a campaign withno expectation of return
beyond the joy ofphilanthropic giving.
3
Donation
DebtEquity
Premium
PoliticalCharity
SocialCauses Creative Endeavors
P2PLending
ProductPre-sale
At RiskCapital
LaunchCapital
ProjectFinancing
GowthCapital
www.communityleader.com
In the reward/premium-basedmodel, investors contributed toa campaign in exchange for amaterial “gift.”
Reward/Premium-based Crowdfunding
In the reward/premium-based model, a donor expects a material "gift" in exchange
for a contribution. Example"gifts" from well-established versions of reward-based
crowdfunding include a raffle ticket for the local schoolfundraiser or a coffee mug
from the community-owned radio stationcampaign. Over the last five years, for-
profit businesses – often start-ups –have leveraged the premium-based
crowdfunding model as a way tofinance the launch of new products. The result is
that these campaignsbecome a pre-sale of a product, which can be in various
stages ofdevelopment. Like the donation-based model, reward/premium-
basedcrowdfunding is relevant to community banks in that it offers a variety
ofavenues to support the local community, organizations and businesses. !While
this series of white papers focuses on security-based crowdfunding specifically, it is
important forcommunity bankers to understand rewards/premium-based
crowdfunding in order to recognize the distinctionbetween these unregulated
models and their securities-based counterparts.
Until 2012, reward- and premium-based crowdfunding were the only legal means
for businesses to leverage thepower of the Internet to attract the growth capital
they needed. This all changed with the passage of the Jumpstart Our Business
Start-Ups (JOBS) Act, which opened the door to new models of crowdfunding in
the United States.iv
4
"Bankers have the business acumen, the financial resources and the 'will' to make
things happen—to contribute to the stewardship of boards and committees in
their community—to enrich the lives of their constituents."
~ Kim Kaselionis, co-author and former CEO/Chairman of Circle Bank
The JOBS Act: Opening Doors
The solicitation and sale of private securities has been a tightly regulated market in the
U.S. since 1933. Theseregulations have restricted how businesses can sell equity or
debt, who can invest in private companies and howthe debt or equity can be sold in
the market. By early 2010, these regulations had created a private securitiesmarket
that failed the vast majority of small and growing businesses in America.
In response to the failures of the market and the emergence of new technologies like
social media, PresidentObama signed the JOBS Act into law in April of 2012, calling it
a "potential game changer."vi The large margin ofthe victory — (the bill passed in the
House of Representatives 390 to 23)vii — is indicative of the bipartisan changein
political attitudes toward crowdfunding as a viable, legitimate vehicle for small and
new businesses to raisecapital.viii
Since the JOBS Act was passed, it has had and continues to have a tremendous
impact on debt-based lending inthis country. While we have yet to experience the
effect of the JOBS Act on equity financing, we can look to thesuccess in other
countries as a proxy for what the U.S. can expect. For example, the Australian Small
Scale Offerings Board ("ASSOB"), the largest crowdfunding platform in Australia and
one of the largest in the world, isan equity-based crowdfunding platform that has
served both accredited and unaccredited investors, raising morethan US $130 million
for issuers since its inception.ix This leaves little doubt that what lies ahead will be
nothingshort of transformative.
Although the name suggests this legislation is relevant only to start-upsand
entrepreneurs, the JOBS Act generates new opportunities for established small
businesses, banks and unaccredited investors as well. There are four keyelements of
the Act: General Solicitation (Title II), Classic Crowdfunding (Title III), RegA+ (Title IV)
and the creation of a new category of issuer, the Emerging Growth Company (EGC).
At US $93 billion, thepotential size of
developing worldcrowdfunding would
represent 1.8 times global venture capital
investments.
(infoDev/The World Bank!)
5
General Solicitation (Title II)
Title II of the JOBs Act lifted the ban on general solicitation of investments, creating
a private security exemption(506c) that allows businesses to take to the Internet,
newspaper, billboards or even the country club to advertisetheir offerings to
prospective investors. Since the most cost-effective general solicitation happens
online, manyportals have launched to support companies in taking advantage of the
506c. These portals often refer to whatthey do as "accredited crowdfunding."
A potential disadvantage of using general solicitation is that 100% of the resulting
investors must be verified asaccredited. The advantage, however, is that
businesses can bypass the traditional gatekeepers and intermediariesthat have
historically restricted their access to prospective investors.
Since community banks traditionally operate within this gatekeeper and
intermediary role, the 506cexemption appears at first glance to simply create a host
of new competition for banks. Equally possible,however, if properly understood and
embraced by banks, the 506c provides new opportunities for communitybank
customers to secure the resources they need to take greater advantage of
traditional banking products andservices.
www.communityleader.com
A community bank client hasthe opportunity to acquire thecommercial buildingtheyoccupy, but they don'thave sufficient cash for thedown payment. The bank canreferthat client to a secureportal through which they canraise the required 20% downfrom"the crowd." The bank canthen provide the SBA or in-house financing necessarytomake the purchase a reality.The business client owns thebuilding, the investors gainastrong position, and the bankhas a new earning asset.
6
The exemption allowing for general solicitation means new competition for
community banks, but it also provides new opportunities for those community
banks that rise to the occasion and meet this change head-on.
JOBS & Community Banks: General Solicitation
Classic Crowdfunding (Title III)
One component of the JOBS Act with particular relevance to the community
banking world involves classiccrowdfunding (Title III). This part of the legislation
provides small businesses with the ability to raise up to $1million during a rolling 12-
month period from an unlimited number of unaccredited investors. In this
model,investors become part of the ownership culture of the business. Who better
to become the greatest evangelistsand supporters of the business than the owners
themselves?
Title III enables entrepreneurs and small business owners to convert their "social
capital" into "financial capital"by transforming their customers, suppliers and
vendors into owners. Raising equity capital strengthens acompany's balance sheet
and, in effect, makes the business more desirable as a borrower. By leveraging
thesenew regulations, community banks may find more of their business clients
becoming eligible for traditional bankfinancing and/or additional fee-based bank
products.
A business client applies for atraditional loan but doesn't
qualify. The bank referstheclient to a crowdfunding
portal through which the clientcan potentially raise
sufficientequity to enhancetheir balance sheet. The bankcan leverage this new capital
to justifya SBA 7a or otherbusiness loan. Now the bank
hasn't simply turned the clientaway,the client has the capital
they need and the bank hasgained a viable lending client.
7
The ability of small businesses to raise money from unaccredited investors
enables them to convert their customers, suppliers and vendors into owners.
The equity capital raised through this process can make the business a
stronger candidate for traditional lending.
JOBS & Community Banks: Classic Crowdfunding
www.communityleader.com
A developer commits to ahigh-profilecommercial/residentialdevelopment on amaincorridor and is seekingcapital. As part of theinvestment package, thedeveloperlaunches a $15million raise using RegA+,which allows both accreditedandunaccredited investors toparticipate. Now able to accesstraditional advertisingchannels,the developer leverages theirbrand and the attractiveness ofthe location topull together anequity position that reducesthe bank risk and decreasesthe overallcost of capital.
RegA+ (Title IV)
Prior to 2012, an exemption known as RegA existed with the intention of allowing
businesses to accessunaccredited investors without the high costs associated with
going public. The RegA exemption, however, waspoorly designed and rarely used;
as such, it did little to help connect businesses with unaccredited investors.
The JOBS Act changed this by overhauling RegA to address various barriers to its
effectiveness, the result ofwhich is being referred to as RegA+. In its new form,
RegA+ allows businesses to raise up to $20 million from anunlimited number of
accredited investors as a low-volume trading, short-form reporting public
offering.According to senior securities attorney and Chief Compliance Officer of
CommunityLeader Rick Weintraub, thenew RegA+ has tremendous potential to
provide the promise of crowdfunding without many of the restrictions,limits and
operational costs.
At a February 2014 forum for community banks hosted by Breakaway Funding,
Weintraub reinforced the fact thatthe new RegA+ will be most attractive to the
construction and development clients whose business is so critical tocommunity
banks. He warned bankers that understanding the implications of RegA+ will be
essential tomaintaining core business lines and remaining competitive as financial
8
The changes to RegA+ are likely to appeal most to the construction and
development clients upon whose business community banks depend on. Thus
bankers must fully understand the implications of RegA+ if they wish compete as
financial service providers.
JOBS & Community Banks: RegA+
Emerging Growth Companies (EGCs)
Another relevant component of the JOBS Act was the creation of a new category of
issuer, the Emerging Growth Company (EGC). An EGC is defined as any private
company with revenues less than $1 billion in the preceding 12 months. The
legislation reduces the disclosure obligations for EGCs, allowing them to file
registrationstatements confidentially and test the waters with large institutional
investors. Before committing to specificterms, EGCs can now solicit investments
and engage in a dialog with potential investors without therestructuring and insider
knowledge concerns previously involved in launching an offering. As a result,
therisks and costs associated with a raise are decreased.
The direct importance of the EGC category creation to community banks is that,
when viewed in connection with the other changes presented by the JOBS Act, it
further demonstrates the major shift of the securities market from one of limitations
with an incredibly small percentage of the population able to access investment
opportunities and small businesses unable to solicit investors to one full of
significant new opportunities for unaccredited investors and companies seeking
growth capital.
9
In conjunction with the other components of the Act, this new category creates
yet another new option for businesses seeking growth capital. Community
banks that embrace these changes will benefit along with their clients; those
that do not will find themselves struggling to survive.
JOBS & Community Banks: EGCs
A business client is tired ofbeing continually turned
down by the bank. Althoughthe client would prefer to
stay with the bank, they areconsidering turning to a non-
bank or soliciting the fundsthey need directly as an EGC.
The community bank stopsthis from happening by
offering the business clientanother option: A
crowdfunding portal throughwhich to raise funds in aregulated environment.
www.communityleader.com
In the debt-based model,funders lend money toindividuals or businessowners expectingrepayment of principal(normally with interest).
In the equity-based model,funders invest in the vision,business plan andmanagement of acompany in return forequity or equity-likeshares.
Equity and Debt-based Crowdfunding
The JOBS Act brought forth two new types of crowdfunding: equity- and debt-
based. Both types are legallyconsidered to be securities and are therefore subject
to government regulation. If the issuer is soliciting andselling an equity position
(stock) in their company, they are engaging in equity-based crowdfunding. If
theoffering is for a debt position, the issuer is using debt-based crowdfunding.
While the JOBS Act deregulated certain aspects of the securities market, it is
important to note that the previous80 years of regulation, case law, policies and
procedures remain inplace. Companies seeking to take advantage of the
newopportunities presented by the JOBS Act will still have to adhere tothese rules.
Unlike the unregulated markets of donation- andreward/premium-based
crowdfunding, securities-basedcrowdfunding provides issuers and investors with
the protectionsassociated with the securities market.
The implications equity- and debt-based crowdfunding will have for community
banks are obvious. Other thancredit cards, friends and family, the financing of
business growth through debt has until now been almostexclusively purveyed by
banks. Therefore, the legalization of debt-based crowdfunding represents a
significant increase in competition for community banks. The businesses that once
relied on banks for debt financing nowhave a large and continually growing set of
options that will directly compete for bank clients. On the other hand, the availability
ofsecurities-based crowdfunding will improve the financial position of many
businesses, allowing them to meet underwriting guidelines for the first time as well
as positioning them to purchase other fee-basedfinancial products. This conversion
of non-borrowers to borrowers through crowdfunding holds significant promise for
community banks.
10
"While others focus on the 'crowd' aspect of the new technology and
deregulations, community bankers will immediately recognize that these emerging
vehicles open the door to more robust 'community'- funding opportunities."
~ Joseph Barisonzi, co-author & CEO CommunityLeader
Crowdfunding Up to the Present
Crowdfunding began as a creative idea for aggregating donors to support social
activities and respond to social needs. As a result of technological advancements
and the many innovative entrepreneurs and business owners who have been
starved for capital, crowdfunding has rapidly become a viable funding alternative
and genuineearthquake shaking the foundation of business financing.
The oft-cited massolution™ Crowdfunding Industry Report (2013)xi predicted that,
by the end of 201 crowdfunding would become a $5.1 billion global market. North
America was expected to contribute a estimated 73% ($3.72 billion) to the global
market share by the end of 2013.
While data for 2013 is still being collected, analyzed and reported, the momentum
of crowdfunding is continuing to take the financial sector by storm. The question at
this point is not whether the crowdfunding industry will demonstrate significant
growth; the question is how much that growth will exceed the expectations of
industry leaders.
Campaign: The three-stage process an
issuergoes through toraise capital and
provideinvestors with areturn on their money.
Thethree stages, asdefined by
CommunityLeader,aredevelopment, raise and
support.
1111
www.communityleader.com
Portal: The front-endmarketing websitethatconnects issuers andinvestors. There are awidevariety of portal types, eachbased on theunderlyingbusiness model of thecrowdfundingendeavor.The use of the term, portal,is derivedfrom the type ofcrowdfunding sitethataggregates multipleissuers during theraisestage of a campaign.
12
The Future of Securities-based Crowdfunding
Over the past several years, there has been a dramatic rise in debt-based crowdfunding
(see "Growth by Model Type"). This increase suggests that society at large ("the crowd")
views this funding vehicle as a viable alternative to traditional bank debt. There is nothing
to suggest its acceptance and popularity will do anything but continue to climb. With
nothing in sight to suggest that underwriting guidelines will loosen up, the prominence of
securities-based crowdfunding is sure to grow in popularity as an alternative capital
funding source over th next 5-10 years.
Michael Porter, whom many consider to be the father of modern competitive strategy,
writes: "Innovation is the central issue in economic prosperity."xii This could not be more
true than it is today. The business capital market demands innovation and a wider array
of options, both of which are provided by crowdfunding. As a result, what began as a
curious trend during a financial crisis has grown into a revolution changing the capital
market forever.
Conclusion
While the word is relatively new and more than trendy, the concept of crowdfunding
has been implemented in various contexts over the past few centuries. From
Benjamin Franklin to the community radio membership campaign, crowdfunding
has proven to be a significant force enabling people to aggregate their economic
power and invest in the issues, companies and projects they believe in.
With the passage of the JOBS Act, several new opportunities have become
available to businesses and investors alike. The options generated by legislative
change combined with the current crunch for capital, technological advances and
increasing acceptance of alternative funding models have created a predicament for
community banks. Changing client expectations and relationships are shifting the
foundation upon which community banks have stood for decades. Bankers are
consistently finding themselves unable to provide clients with the capital they need
due to the limitations of traditional banking environment. Meanwhile, non-bank
competition is rapidly infringing on the funding market previously dominated by
banks.
In light of these challenges, community banks must take immediate action. Bank
decision-makers must decide whether to lead or follow, fight or roll over. In the
current climate of accelerated change, waiting to act means choosing to allow the
evolving demands of the market to cut community banks off from loyal and
prospective clients alike. Banks that fail to act now are likely to find that later is too
late. Community banks that engage recent and future market changes, however,
will find they can use the new characteristics of the market to their advantage.
Fueled by a solid understanding of crowdfunding and the implications of recent
legislature for community banks, bank leaders have an extraordinary opportunity to
leverage crowdfunding in their favor. Community bankers who recognize this
opportunity will meet the challenge head-on and embrace the future of banking on
their own terms.
9 See Section 15(a) of the Securities Exchange Act of 1934 and Regulation 3a4-1promulgated thereunder.
10 Please see “The Roles of the Security Team”on page 18
About the Authors
www.communityleader.com
Joseph Barisonzi, [email protected]
Joseph Barisonzi is the Co-founder and CEO of CommunityLeader, Inc.
CommunityLeader is the premier provider of platform solutions for the online
solicitation, sale and support of private securities. CommunityLeader's integrated,
white-labled platform is used by many of the leading crowdfunding sites in the United
States. Mr. Barisonzi has co-authored numerous whitepapers on crowdfunding and
published "Navigating your Portal Launch" as an eBook in 2013.
An accomplished senior executive with over 20 years of leadership experience in
community and business development, Mr. Barisonzi is one of the leading voices for
a community-based approach to crowdfunding. Mr Barisonzi resides with his spouse
and daughter in Minnesota, where he is active with many community and civic
organizations.
Kim Kaselionis, founder & managing [email protected]
Kim Kaselionis is the former CEO/Chairman of Circle Bank, where she led the
Northern California Community Bank to 53 consecutive profitable quarters and
developed the brand from a single-branch bank to one with six locations, managing
more than $300 million in total assets. Under the leadership of Ms. Kaselionis, the
once near-insolvent bank was sold to Umpqua Bank in late 2012.
Winner of numerous industry and community awards, Ms. Kaselionis aims to utilize
her 20 years of community banking expertise to become the leader in community
banking via the facilitation of crowdfunded equity and debt.
i "The Library Company." USHistory.org, N.d. <http://www.ushistory.org/franklin/philadelphia/library.htm> Web. 20 March 2014.
ii "Pulitzer - In Depth." National Park Service. 4 March 2014. <http://www.nps.gov/stli/historyculture/pulitzerin- depth.htm> Web. 17
March 2014.
iii Barisonzi, Joseph. Navigating Your Portal Launch. CommunityLeader, Inc., 2013. www.communityleader.com.
iv U.S. Congress. House. Jumpstart Our Business Start-ups Act. HR 3606. 112th Cong., 2nd sess. Congressional Record 39. 3
January 2012. <http://www.gpo.gov/fdsys/pkg/BILLS-112hr3606enr/pdf/ BILLS-112hr3606enr.pdf> Web. 20 May 2014.
v Barisonzi, Joseph and Kim Kaselionis. "Banking with Purpose." Community Banks: Renewed Purpose and Survival through
Crowdfunding. 29 April 2014. <http://www.breakawayfunding.com/forbanks/#whitepaper> Web 5 May 2014.
vi Transcript, President Barack Obama, "Remarks by the President at JOBS Act Bill Signing." The White House. 5 April 2012.
<http://www.whitehouse.gov/photos-and-video/video/2012/04/05/president-obama-signs-jobsact# transcript> Web 5 May 2014.
vii "Final Vote Results for Roll Call 110." U.S. House of Representatives 3606 Recorded Vote, 8 March 2012.
<http://clerk.house.gov/evs/2012/roll110.xml > Web. 29 April 2014.
viii Weisman, Jonathan. "With November in Mind, House Passes a Jobs Bill." The New York Times, March 8, 2012.
<http://www.nytimes.com/2012/03/09/us/politics/house-passes-jobs-act-by-large-margin.html> Web. 4 April 2014.
ix The World Bank. "2013 Information for Development Program (infoDev)."
x The World Bank. "2013 Information for Development Program (infoDev)."
xi 2013CF: The Crowdfunding Industry Report. massolution™. < http://www.crowdsourcing.org/editorial/ 2013cf-the-crowdfunding-
industry-report/25107> Web 18 March 2014.
xii Porter, Michael. "The Five Competitive Forces that Shape Strategy." Harvard Business Review, January 2008.
http://hbr.org/2008/01/the-five-competitive-forces-that-shape-strategy/ar/1.
End Notes
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